SEC Petition Evaluation Report 

Petition SEC-00173 

Report Rev #: 0 Report Submittal Date: January 24, 2011

Subject Expert(s): Mike Mahathy

Site Expert(s): N/A

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Receipt Date 

Qualification 

Date 

DOE/AWE Facility Name 

SEC-00173 83.13 May 17, 2010 July 21, 2010 Norton Co. 

Petitioner Class Definition 

All employees of the Norton Company who worked in any building or area at the Norton Company location on 

New Bond Street in Worcester, Massachusetts, from 1960 through 1972. 

Class Evaluated by NIOSH 

All atomic weapons employees who worked in any building or area at the facility owned by the Norton Co. in 

Worcester, Massachusetts, during the residual radiation period from January 1, 1958 through October 31, 2009. 

NIOSH-Proposed Class to be Added to the SEC 

All atomic weapons employees who worked in any building or area at the facility owned by the Norton Co. (or a 

subsequent owner) in Worcester, Massachusetts, during the period from January 1, 1958 through October 10, 

1962, for a number of work days aggregating at least 250 work days, occurring either solely under this 

employment or in combination with work days within the parameters established for one or more other classes of 

employees included in the Special Exposure Cohort. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

SEC-00148 83.14 Norton Co. Class added to SEC 

(January 1945-December 1957) 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

SEC Petition Evaluation Report for Petition SEC-00148 (January 1, 1945 through 

December 31, 1957) 

Norton Co. 

ORAU Lead Technical Evaluator: Mike Mahathy ORAU Peer Review Completed By: Michael Kubiak 

Peer Review Completed By: [Signature on file] 1/24/2011 

Frank C. Crawford Date 

[Signature on file] 1/25/2011 SEC Petition Evaluation Reviewed By: 

J. W. Neton Date 

[Signature on file] 1/26/2011 SEC Evaluation Approved By: 

Stuart L. Hinnefeld Date 
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Evaluation Report Summary: SEC-00173, Norton Co. 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00173 was received on May 17, 2010, and qualified on July 21, 2010. The petitioner 

requested that NIOSH consider the following class: All employees of the Norton Company who 

worked in any building or area at the Norton Company location on New Bond Street in Worcester, 

Massachusetts, from 1960 through 1972.

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH modified the petitioner-requested class. NIOSH evaluated 

the following class: All atomic weapons employees who worked in any building or area at the facility 

owned by the Norton Co. in Worcester, Massachusetts, during the residual radiation period from 

January 1, 1958 through October 31, 2009. The class under evaluation was expanded beyond that 

requested by the petitioner to provide a comprehensive review of the entire residual radiation period at 

Norton Co. 

NIOSH-Proposed Class to be Added to the SEC

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all atomic weapons employees who worked in any building or area at the 

facility owned by the Norton Co. (or a subsequent owner) in Worcester, Massachusetts, during the 

period from January 1, 1958 through October 10, 1962, for a number of work days aggregating at 

least 250 work days, occurring either solely under this employment or in combination with work days 

within the parameters established for one or more other classes of employees included in the Special 

Exposure Cohort. NIOSH has determined that decontamination and decommissioning activities were 

conducted during the period from January 1, 1958 through October 10, 1962, for which NIOSH has 

insufficient source term and monitoring data to bound internal and external doses potentially received 

from exposures during that work. 

NIOSH finds that it does have sufficient data to bound doses for the period from October 11, 1962 

through October 31, 2009 (the end of the designated residual radiation period). For this period, 

NIOSH has obtained gross alpha air monitoring results collected at Norton Co. near the end of the 

Atomic Weapons Employer (AWE) operations period and during the residual radiation period. Using 

those data and the guidance in ORAUT-OTIB-0070, NIOSH can bound the internal doses potentially 

received from exposures to residual uranium and thoria. NIOSH can use the same set of gross alpha 

data to bound potential internal doses received from thoron by using decay and in-growth calculations 
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on sample recounts. The gross alpha air contamination data from the operational period and the 

methods described in Battelle-TBD-6000 allow NIOSH to bound external doses from residual 

uranium and thoria. 

Feasibility of Dose Reconstruction

NIOSH finds it is not feasible to estimate internal and external exposures with sufficient accuracy for 

all workers at the site from January 1, 1958 through October 10, 1962, due to decontamination and 

decommissioning activities conducted during that period for which NIOSH has insufficient source 

term and monitoring data to bound potential doses. With the exception of this class, per EEOICPA 

and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient information to: (1) 

estimate the maximum radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could have been incurred in plausible circumstances by any member of the class; or 

(2) estimate radiation doses more precisely than an estimate of maximum dose. Information available 

to NIOSH is sufficient to document or estimate the maximum internal and external potential exposure 

to members of the evaluated class under plausible circumstances during the period from October 11, 

1962 through October 31, 2009. 

The NIOSH dose reconstruction feasibility findings are based on the following: 

• NIOSH has determined that, although AWE operations were not performed at Norton Co. after 

1957, Norton Co. performed decontamination and decommissioning of AWE materials and wastes 

from January 1, 1958 through October 10, 1962, which potentially exposed Norton Co. workers to 

internal and external radiation. 

• Principal sources of internal radiation for members of the proposed class included exposures to 

residual natural uranium and thorium metals, as well as associated dusts. The modes of exposure 

were inhalation and ingestion during the clean-up of these metals. 

• Principal sources of external radiation for members of the proposed class included exposures to 

gamma and beta radiation associated with decontamination and decommissioning of the residual 

AWE materials and wastes. The modes of exposure were submersion in potentially-contaminated 

air and exposure to contaminated surfaces. 

• NIOSH lacks sufficient source term and monitoring data to bound doses potentially received from 

exposures during the decontamination and decommissioning of AWE materials and wastes from 

January 1, 1958 through October 10, 1962. 

• Based on lack of sufficient monitoring data for Norton Co. workers or operations, internal and 

external dose reconstruction for the portion of the Norton Co. residual radiation period from 

January 1, 1958 through October 10, 1962, is not feasible. 

• NIOSH has identified sufficient information and data to support bounding internal dose for the 

remaining portion of the residual radiation period (October 11, 1962 through October 31, 2009) 

using air monitoring data obtained during the operational period and guidance given in ORAUT-
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OTIB-0070, Dose Reconstruction during Residual Radioactivity Periods at Atomic Weapons 

Employer Facilities. 

• Doses received from occupational medical X-rays are not considered part of the source term for 

the residual radiation period; therefore, medical doses were not evaluated. 

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information (for 

the period from January 1, 1958 through October 10, 1962) to either: (1) estimate the maximum 

radiation dose, for every type of cancer for which radiation doses are reconstructed, that could 

have been incurred under plausible circumstances by any member of the class; or (2) estimate the 

radiation doses of members of the class more precisely than a maximum dose estimate. 

• Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed 

at Norton Co. during the period from January 1, 1958 through October 10, 1962, but who do not 

qualify for inclusion in the SEC, may be performed using these data as appropriate. 

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class for the period from January 1, 1958 through October 10, 1962. 

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that the proposed class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures. However, evidence indicates that some workers in the 

proposed class may have accumulated substantial chronic exposures through episodic intakes of 

radionuclides, combined with external exposures to gamma and beta radiation. Consequently, NIOSH 

has determined that health was endangered for those workers covered by this evaluation who were 

employed for at least 250 aggregated work days either solely under this employment or in 

combination with work days within the parameters established for one or more other SEC classes. 

For the remainder of the residual period from October 11, 1962 through October 31, 2009, a health 

endangerment determination is not required because NIOSH has determined that it has sufficient 

information to estimate dose for the members of the evaluated class. 
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Table of Contents 

1.0 Purpose and Scope .......................................................................................................................... 9

2.0 Introduction .................................................................................................................................... 9

3.0 SEC-00173 Norton Co. Class Definitions .................................................................................... 10

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 10

3.2 Class Evaluated by NIOSH ................................................................................................. 11

3.3 NIOSH-Proposed Class to be Added to the SEC ................................................................ 11

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 11

4.1 Site Profile Technical Basis Documents ............................................................................. 12

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 12

4.3 Facility Employees and Experts .......................................................................................... 12

4.4 Previous Dose Reconstructions ........................................................................................... 13

4.5 NIOSH Site Research Database .......................................................................................... 13

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 13

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 14

5.1 Norton Co. Plant and Process Descriptions ......................................................................... 14

5.2 Radiological Exposure Sources from Norton Co. Operations ............................................. 15

5.2.1 Internal Radiological Exposure Sources from Norton Co. Operations ................... 16

5.2.2 External Radiological Exposure Sources from Norton Co. Operations .................. 16

5.2.2.1 Photon ....................................................................................................... 16

5.2.2.2 Beta ........................................................................................................... 18

5.2.2.3 Neutron ..................................................................................................... 18

5.2.3 Incidents .................................................................................................................. 18

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 19

6.1 Available Norton Co. Internal Monitoring Data ................................................................. 19

6.2 Available Norton Co. External Monitoring Data ................................................................ 22

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 23

7.1 Pedigree of Norton Co. Data ............................................................................................... 23

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 23

7.1.2 External Monitoring Data Pedigree Review ............................................................ 25

7.2 Evaluation of Bounding Internal Radiation Doses at Norton Co. ....................................... 26

7.2.1 Evaluation of Bounding Residual Radiation Period Internal Doses ....................... 26

7.2.1.1 Urinalysis Information and Available Data .............................................. 26

7.2.1.2 Airborne Levels ........................................................................................ 26

7.2.2 Methods for Bounding Residual Radiation Period Internal Dose at Norton Co. .... 27

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ............................................. 29

7.3 Evaluation of Bounding External Radiation Doses at Norton Co. ...................................... 29

7.3.1 Evaluation of Bounding Residual Radiation Period External Doses ...................... 29

7.3.2 Norton Co. Occupational X-Ray Examinations ...................................................... 29
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7.3.3 Methods for Bounding Residual Radiation Period External Dose at Norton Co. ... 30

7.3.4 External Dose Reconstruction Feasibility Conclusion ............................................ 30

7.4 Evaluation of Petition Basis for SEC-00173 ....................................................................... 31

7.4.1 Petition Basis ........................................................................................................... 31

7.4.2 Waste Disposal Area on I-190 Ramp ...................................................................... 31

7.5 Summary of Feasibility Findings for Petition SEC-00173 .................................................. 31

8.0 Evaluation of Health Endangerment for Petition SEC-00173 ...................................................... 32

9.0 Class Conclusion for Petition SEC-00173 ................................................................................... 33

10.0 References .................................................................................................................................... 35

Attachment 1: Data Capture Synopsis ................................................................................................... 41

Tables 

Table 4-1: No. of Norton Co. Claims Submitted Under the Dose Reconstruction Rule ....................... 13 

Table 5-1: Principal Radiation Emissions from Natural Uranium and Its Short-Lived Decay 

Products .............................................................................................................................. 17

Table 5-2: Principal Radiation Emissions from Th-232 and its Short-Lived Decay Products ............. 17 

Table 7-1: Air Monitoring Results, Long-Lived Alpha Emitters .......................................................... 27

Table 7-2: Intake Rates for Uranium or Thorium ................................................................................. 28

Table 7-3: Air Monitoring Results, Short-Lived Alpha Emitters .......................................................... 28

Table 7-4: Intake Rates for Thoron ....................................................................................................... 28

Table 7-5: External Dose Rates for the Residual Radiation Period ...................................................... 30

Table 7-6: Summary of Feasibility Findings for SEC-00173 ............................................................... 32
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SEC Petition Evaluation Report for SEC-00173 

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: Mike 

Mahathy, Oak Ridge Associated Universities. The rationales for all conclusions in this document are 

explained in the associated text.

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all atomic weapons employees who 

worked in any building or area at the facility owned by the Norton Co. in Worcester, Massachusetts, 

during the period from January 1, 1958 through October 31, 2009. It provides information and 

analyses germane to considering a petition for adding a class of employees to the congressionallycreated SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004.1

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

 

1

 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS). 

2

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 
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radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for one or more other SEC 

classes (excluding aggregate work day requirements). 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and to the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.3

 

3.0 SEC-00173 Norton Co. Class Definitions 

The following subsections address the evolution of the class definition for SEC-00173, Norton Co. 

When a petition is submitted, the requested class definition is reviewed as submitted. Based on its 

review of the available site information and data, NIOSH will make a determination whether to 

qualify for full evaluation all, some, or no part of the petitioner-requested class. If some portion of the 

petitioner-requested class is qualified, NIOSH will specify that class along with a justification for any 

modification of the petitioner-requested class. After a full evaluation of the qualified class, NIOSH 

will determine whether to propose a class for addition to the SEC and will specify that proposed class 

definition. 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00173 was received on May 17, 2010, and qualified on July 21, 2010. The petitioner 

requested that NIOSH consider the following class: All employees of the Norton Company who 

worked in any building or area at the Norton Company location on New Bond Street in Worcester, 

Massachusetts, from 1960 through 1972 (Petition, 2010).

The petitioner provided information in support of the petitioner’s belief that accurate dose 

reconstruction over time is impossible for the Norton Co. workers in question because radiation 

monitoring records have been lost, falsified, or destroyed; or that there is no information regarding 

3

 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 
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monitoring, source, source term, or process from the site where the employees worked. By requesting 

this basis, the petitioner did not need to establish (through documentation or affidavit) that there are 

no monitoring records whatsoever for personal or area monitoring that was conducted for the class of 

employees, or that all the relevant records have been falsified. 

Based on its Norton Co. research and data capture efforts, NIOSH determined that it lacks access to 

external and internal monitoring data for Norton Co. workers during the time period under evaluation. 

NIOSH also determined that air monitoring records are available for some of the time period for all 

radionuclides. NIOSH concluded that there is sufficient documentation to support, for at least part of 

the requested time period, the petition basis that radiation monitoring records for members of the 

proposed class have been lost, falsified, or destroyed; or that there is no information regarding 

monitoring, source, source term, or process from the site where the employees worked. The 

information and statements provided by the petitioner qualified the petition for further consideration 

by NIOSH, the Board, and HHS. The details of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH modified the petitioner-requested class to provide a 

comprehensive review of the entire residual radiation period at Norton Co. Therefore, NIOSH defined 

the following class for further evaluation: All atomic weapons employees who worked in any building 

or area at the facility owned by the Norton Co. in Worcester, Massachusetts, during the residual 

radiation period from January 1, 1958 through October 31, 2009. 

3.3 NIOSH-Proposed Class to be Added to the SEC 

Based on its research of the class under evaluation, NIOSH has defined a single class of employees for 

which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH-proposed class 

to be added to the SEC includes all atomic weapons employees who worked in any building or area at 

the facility owned by the Norton Co. (or a subsequent owner) in Worcester, Massachusetts, during the 

period from January 1, 1958 through October 10, 1962, for a number of work days aggregating at 

least 250 work days, occurring either solely under this employment or in combination with work days 

within the parameters established for one or more other classes of employees included in the Special 

Exposure Cohort. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

As a standard practice, NIOSH completed an extensive database and Internet search for information 

regarding the Norton Co. The database search included the DOE Legacy Management Considered 

Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, the Energy 

Citations database, the Atomic Energy Technical Report database, and the Hanford Declassified 

Document Retrieval System. In addition to general Internet searches, the NIOSH Internet search 

included OSTI OpenNet Advanced searches, OSTI Information Bridge Fielded searches, Nuclear 

Regulatory Commission (NRC) Agency-wide Documents Access and Management (ADAMS) web 

searches, the DOE Office of Human Radiation Experiments website, and the DOE-National Nuclear 
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Security Administration-Nevada Site Office-search. Attachment One contains a summary of Norton 

Co. documents. The summary specifically identifies data capture details and general descriptions of 

the documents retrieved. 

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. Although no Site Profile has been written for Norton Co., the following 

Technical Basis Documents were reviewed in support of this evaluation. 

• Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium Metals, BattelleTBD-6000; Rev. F0; December 13, 2006; SRDB Ref ID: 30671 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

guidance for preparing dose reconstructions at particular sites or categories of sites. An ORAU 

Procedure provides specific requirements and guidance regarding EEOICPA project-level activities, 

including preparation of dose reconstructions at particular sites or categories of sites. NIOSH 

reviewed the following OTIB as part of its evaluation: 

• OTIB: Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070, Rev. 00; March 10, 2008; SRDB Ref ID: 41603

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed three former Norton Co. employees: 

• Personal Communication, 2010a, Personal Communication with Former Norton Co. Industrial 

Health Care Worker; Telephone interview; September 14, 2010; SRDB Ref ID: 88131 

• Personal Communication, 2010b, Personal Communication with Former Norton Co. 

Machinist/Foreman; Telephone interview; September 14, 2010; SRDB Ref ID: 88133 

• Personal Communication, 2010c, Personal Communication with Norton Co. Communications 

Specialist; Telephone interview; September 21, 2010; SRDB Ref ID: 90292
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4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review. (NOCTS data available as of December 19, 2010) 

Table 4-1: No. of Norton Co. Claims Submitted Under the Dose Reconstruction Rule 

Description Totals 

Total number of claims submitted for dose reconstruction 64 

Total number of claims submitted for energy employees who worked at any time during the period 

under evaluation (January 1, 1958 through October 31, 2009). 56 

Number of dose reconstructions completed for energy employees who worked at any time during the 

period under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 18 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 0 

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 0 

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the claimant. As noted in Table 4-1, NIOSH has not received external 

or internal monitoring data from Norton Co. for any claimants. Of the eighteen dose reconstructions 

submitted by NIOSH for energy employees who worked during the period under evaluation, seven 

were full dose reconstructions and eleven were performed using overestimates. 

4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. One hundred forty-seven documents in this database were 

identified as pertaining to Norton Co. (as of December 19, 2010). Of these, fifty-four were added 

after the date of NIOSH’s last 83.14 SEC Evaluation (SEC-00148). These documents were evaluated 

for their relevance to this petition. The documents include historical background on the site and 

processes, air monitoring data, direct and removable contamination survey data, external radiation 

survey data, external monitoring data, and limited bioassay data.

4.6 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioners: 

• 83.13 Form B Special Exposure Cohort Petition and supporting documents, received by NIOSH 

on May 17, 2010 (Petition, 2010) 
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5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize both radiological operations at the Norton Co. from January 

1958 to October 2009 and the information available to NIOSH to characterize particular processes and 

radioactive source materials. AWE operations conducted onsite during the period from 1945 through 

1957 determine the source term for the residual radiation period currently under evaluation. From 

available sources NIOSH has gathered process and source descriptions, information regarding the 

identity (and some information about quantities) of each radionuclide of concern, and information 

describing processes through which radiation exposures may have occurred and the physical 

environment in which they may have occurred. The information included within this evaluation 

report is intended only to be a summary of the available information. 

5.1 Norton Co. Plant and Process Descriptions 

The purpose of this report is to evaluate exposures during the residual radiation period from January 

1958 through October 2009; however, the EEOICPA-covered AWE operations at the Norton Co. 

facility (1945-1957) are summarized below because the source term for the residual radiation period is 

determined by the nature of the work conducted during the AWE operations period. 

Norton Co. was located in Worcester, Massachusetts on a multi-building site consisting of over 100 

acres. Building 112, a 50,000 square-feet building where Norton Co. conducted AWE radiological 

operations from 1945 through 1957, was located on the south end of the site (Radiation Safety 

Associates, 1997a). NIOSH has been unable to determine the size of the Norton Co. workforce for 

either the AWE period (1945-1957) or the residual radiation period under evaluation. 

In 1945, under a Manhattan Engineer District (MED) contract, Norton Co. started fabricating 

hexagons containing beryllium oxide-uranium oxide at both the Worcester site and at Norton’s 

Chippewa site in Ontario, Canada. The hexagon work at Worcester was performed on a laboratory 

scale until full production began soon after May 1947 (Randall, 1947, pdf p. 5). NIOSH has no 

information on the amount of uranium used in the hexagon process. In May 1947, the Atomic Energy 

Commission (AEC) asked Norton Co. to fabricate ten beryllium oxide cubes containing ten percent 

U3O8 by weight (Unidentified author, 1947). Additional orders were placed in 1947 for small 

quantities of beryllium cylinders (30 or less) containing uranium from either UO2 or U3O8 (Daume, 

1947). NIOSH has obtained data on a portion of the uranium inventory at Worcester (Inventory, 

various dates). Norton Co. provided UO2 to the AEC in 1949 from stored materials (DOE, unknown 

date). In 1953, Norton Co. shipped scrap to Fernald for recovery of about 160 kilograms of uranium 

(Bate, 1953; Rudolph, 1953). Norton Co. continued making crucibles and cylinders containing some 

amount of uranium through at least 1954 (Harris, 1954; Henson, 1954a; Braiden, 1954). NIOSH has 

obtained survey results and urinalysis data that demonstrate that uranium was on site through at least 

1956 (Benedict, 1956; Urinalysis, 1956). 

By 1949, Norton Co. was producing materials using thorium (Geo Survey, 1949). Norton Co. made 

crucibles containing varying percentages of thorium and also produced an oxide compound known as 

“Norton fused oxide” (Henson, 1954b). In 1957, about twenty-five Norton Co. employees worked in 

the AWE programs (Personal Communication, 2010a). All work with radioactive materials (both 
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AWE and commercial) was performed in a building identified as Building 112 in a 1996 survey 

(Radiation Safety Associates, 1997a). 

During the period from January 1, 1958 through October 7, 1962, in Building 112, Norton Co. 

employees performed tear-down operations and removed materials used in the AWE radioactive 

processes (e.g., refractory materials, equipment, and wastes) and performed contamination clean-up. 

After removing materials and performing clean-up activities, Norton Co. continued to conduct 

commercial thorium operations in Building 112 (Personal Communication, 2010a). As part of the 

AWE clean-up, areas, equipment, and materials used in AWE operations were cleaned with the debris 

being stored in drums and barrels. Refractory kilns and furnaces were dismantled brick-by-brick and 

transferred to barrels. Other equipment and materials were solvent-washed, dried with paper towels, 

dismantled, and transferred to barrels. Surface areas of the building were cleaned and the residue 

placed in barrels. The dismantling and cleaning processes sometimes led to dusty conditions 

(Personal Communication, 2010a). Materials removed included ceramic, aluminum oxide, silicon, 

carbide and zirconium oxide, bricks, batts, sagger plates, ventilation and dust collecting apparatus, 

pipes, and sheet steel pipe; all of these items came in contact with natural insoluble thoria (Th-232) 

and natural insoluble urania (U-238) (Mondor, 1962; Johnson, 1961; Johnson, 1962). In all, 287 

barrels (25-gallon, 35-gallon, and 55-gallon) of materials and waste were collected. Norton Co. 

estimated that the gross weight of the barrels was between 18 to 20 tons and that the amount of 

radioactive materials present in that gross amount was 15 pounds of thorium and 25 pounds of 

uranium (Johnson, 1962).

 

Between October 8 and October 10, 1962, Norton Co. employees (Mondor, 1962) transported the 

wastes to a portion of the Norton Co. landfill and buried the wastes at a 30-foot depth (Personal 

Communication, 2010a; Petition, 2010, pdf p. 25; Mondor, 1962). The burial was monitored by 

Norton Co. Hygiene and Safety (Mondor, 1962). NIOSH further learned that some of that landfill 

was transferred to the State of Massachusetts for highway construction (Personal Communication, 

2010a). 

Norton Co. possessed an AEC material license (STB-00770) for commercial purposes through 1967, 

with that work being performed in Building 112 as well (Radiation Safety Associates, 1997a). 

Contamination resulting from such commercial work was not considered in this evaluation report. 

5.2 Radiological Exposure Sources from Norton Co. Operations 

For employment during the residual radiation period, only the radiation exposures defined in 42 

U.S.C. § 7384n(c)(4) [i.e., radiation doses received from DOE-related work] must be included in dose 

reconstructions. That is, internal or external radiation exposure associated with commercial sources of 

exposure is not reconstructed. For example, the exposure incurred from the manufacture and 

distribution of commercial uranium and/or thorium products would not be reconstructed during the 

residual radiation period (NIOSH, 2009). However, under subparagraph B of 42 U.S.C. § 

7384n(c)(4), radiation from a source that cannot be reliably distinguished from radiation covered 

under subparagraph A (i.e., radiation doses received from DOE-related work) is considered part of the 

employee’s radiation dose and must be reconstructed (NIOSH, 2009). 

During the residual radiation period, doses associated with radiation or radiation-generating devices 

used at the AWE facility for commercial purposes that are distinguishable from the non-commercial 
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sources are not included in the dose reconstruction. This includes, but is not limited to, doses from: 

(1) non-destructive testing devices such as radiography units; (2) process or flow gauges that employ 

radioactive sources; (3) moisture or density gauges; (4) electrostatic eliminators; and (5) radiationgenerating laboratory instruments, such as X-ray diffraction units (NIOSH, 2009). 

During the decontamination and decommissioning portion of the residual radiation period at the 

Norton Co. site, the primary source of exposures would have been from tear-down, clean-up, and 

removal of any remaining source materials and contaminated building materials and equipment. 

The following subsections provide an overview of the internal and external exposure sources for 

Norton Co. operations that affect the residual radiation period under evaluation. 

5.2.1 Internal Radiological Exposure Sources from Norton Co. Operations 

During the residual radiation period currently under evaluation (January 1, 1958 through October 31, 

2009), the primary source for internal exposure would have been from tear-down, clean-up, and 

disposal of the contaminated equipment and other materials used during the operational period as well 

as re-suspension of contamination. NIOSH has documentation showing that 15 pounds of thorium 

and 25 pounds of uranium were removed from Building 112 and buried in October 1962 (Mondor, 

1962). Norton Co. workers dressed out in company-provided clothing, shoes, and gloves during these 

operations. Mine Safety Administration (MSA) dust respirators were sometimes used (Personal 

Communication, 2010a); however, NIOSH has no documentation to support airborne dust levels, how 

often respirators were used, or how respirators were fit-tested. Norton Co. workers showered in the 

hot shower room before entering the cold locker room. 

5.2.2 External Radiological Exposure Sources from Norton Co. Operations 

As established, uranium and thorium were used during Norton Co.’s AWE operations (NIOSH, 2009). 

During the residual radiation period currently under evaluation (January 1, 1958 through October 31, 

2009), workers were potentially exposed to direct radiation from surface contamination as well as 

exposure resulting from submersion in air contaminated with re-suspended residual uranium and 

thorium. This would include re-suspension from incidental removal of residual contamination. 

5.2.2.1 Photon

The majority of the photons from natural uranium metals are in the 30-250 keV energy range. Solid 

uranium objects provide considerable shielding of the lower-energy photons and harden the spectrum, 

causing the majority of the photons emitted from a solid uranium object (such as a billet or rod) to 

have energies greater than 250 keV. While it is recognized that solid uranium sources will have a 

hardened photon spectrum, exposure to a thin layer of uranium on a surface will result in a larger 

fraction of exposure to lower-energy photons (Battelle-TBD-6000). 

Table 5-1 shows the primary isotopes and photon energies associated with the recovery and clean-up 

of uranium. Exposure to these photons was possible during the residual radiation period from direct 

radiation during metal-handling and to submersion in metal-contaminated air. 
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Table 5-1: Principal Radiation Emissions from Natural Uranium and Its Short-Lived Decay Products 

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV) 

U-238 4.468 x 109 years None x: 0.013 (8.8%) 

Th-234 24.1 days 0.096 (25%) x: 0.013 (9.6%) 

0.189 (73%) γ: 0.063 (3.8%) 

γ: 0.093 (5.4%)

Pa-234m 1.17 minutes 2.28 (98.6%) γ: 0.765 (0.2%)

~1.4 (1.4%) γ: 01.001 (0.6%)

U-235 7.038 x 109 years None x: 0.013 (31%) 

x: 0.090-0.105 (9.3%)

γ: 0.144 (10.5%)

γ: 0.163 (4.7%)

γ: 0.186 (54%)

γ: 0.205 (4.7%) 

Th-231 25.5 hours 0.206 (15%) x: 0.013 (71%)

0.288 (49%) γ: 0.026 (14.7%)

0.305 (35%) γ: 0.084 (6.4%)

U-234 244,500 years None x: 0.013 (10.5%)

γ: 0.053 (0.2%) 

Source: Battelle-TBD-6000, pdf p. 20. The table shows the principal radiation emissions from natural uranium and its 

short-lived decay products that were of concern for external radiation (not including bremsstrahlung). 

Thorium has a significant number of higher-energy photons in the Th-232 decay chain. Based on the 

half-lives of the progeny, only a partial equilibrium is possible; therefore, it is conservative to state 

that equilibrium would be reached in this decay chain. It has been assumed that Ra-228 and Th-228 

progeny were in equilibrium with Th-232 during the residual radiation period. Therefore, air 

concentrations were assumed equal for all progeny. Under this assumption, the progeny are the major 

source of both penetrating and non-penetrating external exposure. Table 5-2 shows the primary 

isotopes and photon energies associated with Th-232 and its progeny. 

Table 5-2: Principal Radiation Emissions from Th-232 and its Short-Lived Decay Products 

Table 5-2 spans two pages. 

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV) 

Th-232 1.405 x 1010 years None 0.059 (0.19%) 

0.126 (0.04%) 

Ra-228 5.71 years 0.389 (100%) 0.0067 (6 x 10-5%) 

Ac-228 6.25 hours 0.983 (7%) 0.338 (11.4%) 

1.014 (6.6%) 0.911 (27.7%) 

1.115 (3.4%) 0.969 (16.6%) 

1.17 (32%) 1.588 (3.5%) 

1.74 (12%) --- 

2.08 (8%) --- 

(+33 more βs) --- 
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Table 5-2: Principal Radiation Emissions from Th-232 and its Short-Lived Decay Products 

Table 5-2 spans two pages. 

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV) 

Th-228 1.9116 years None 0.084 (1.19%) 

0.132 (0.11%) 

0.166 0.08%) 

0.216 (0.27%) 

Bi-212 60.55 minutes 1.59 (8%) 0.040 (1%) 

2.246 (48.4%) 0.727 (11.8$) 

--- 1.620 (2.75%) 

Tl-208 3.1 minutes 1.28 (25%) 0.277 (6%) 

1.52 (21%) 0.5108 (21.6%) 

1.80(50%) 0.583 (85.8%) 

--- 0.860 (12%) 

--- 2.614 (100%) 

Source: Handbook of Health Physics and Radiological Health (Rad Handbook, 1998). Intensities refer to the percentage 

of disintegrations of the nuclide itself, not to original parent of series. Gamma percents are given in terms of observable 

emissions, not transitions. 

5.2.2.2 Beta

Tables 5-1 and 5-2 show the principal beta emitters and their energies for the uranium and thorium 

metal used during the residual radiation period. As indicated in these tables, there are a significant 

number of high-energy beta radiations that represent a shallow dose exposure concern to site workers. 

Workers who handled the uranium and thorium metal would have received shallow dose exposures. 

The primary exposure areas would have been the hands and forearms, the neck and face, and other 

areas of the body that might not have been covered. 

5.2.2.3 Neutron

Neutrons were not measured at Norton Co. during the AWE operations period. During the AWE 

operations period, Norton Co. did fabricate hexagon fuel elements containing uranium oxide and 

beryllium; therefore, neutrons could have arisen from the α-n reaction with light elements, interactions 

with the oxides, and through spontaneous fission. Data provided in Battelle-TBD-6000 show that 

during the residual radiation period, any neutron dose rate would be negligible compared to 

beta/gamma dose rates in dose calculations. 

5.2.3 Incidents 

During the dismantling, clean-up, and disposal of AWE equipment and materials, Norton Co. workers 

encountered some material spills. The interview source for this information stated the spills were 

small; however, no quantifications were provided (Personal Communication, 2010a). Spill areas were 

cleaned and checked for surface contamination using the contamination limits that were in place in 

1962. According to an interview with a former Norton Co. employee, reports of all incidents were 

prepared and copies were sent to the Norton Co. medical director and to company management 
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(Personal Communication, 2010a). NIOSH has not identified any documentation on Norton Co. 

incidents. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Norton Co. class under evaluation. 

6.1 Available Norton Co. Internal Monitoring Data 

Norton Co. records were reviewed to identify internal monitoring data. The available data are in the 

form of in vitro bioassay data, air monitoring data, and area survey data. 

In vitro Bioassay Data

Thirty-one in vitro bioassay sample results were identified in the Norton Co. records available to 

NIOSH. There is no information available on the minimum detectable activities or the counting 

systems used for any of these samples. 

• Five samples were submitted to the AEC’s New York Operations Office Health and Safety 

Laboratory (HASL) on June 14, 1955 and were analyzed by fluorometry for uranium (Urinalysis, 

1955). 

• Eight samples were submitted to HASL on December 17, 1956 (Urinalysis, 1956) and analyzed by 

fluorometry for uranium. 

• Seven samples were taken on July 11, 1957 during a radiological survey by the Massachusetts 

Department of Labor and Industries, Division of Occupational Hygiene. These samples were 

analyzed for Pb-212; however, there is no indication who conducted the analysis (Elkins, 1957). 

• Eleven samples were taken during a Massachusetts Department of Labor and Industries survey 

conducted on May 13, 1958. These samples were analyzed for Pb-212 and are the only samples 

taken during the class period under evaluation (Pagnotto, 1958). 

Air Monitoring Data

Ninety-eight air monitoring results were identified in the Norton Co. records available to NIOSH (8 

from 1955; 41 from 1957; 44 from 1958; and 5 total from 1962, 1963, and 1964). 

• Two samples were collected on June 3, 1955 by the Norton Co. and counted on a low-background 

counting system in an argon-methane atmosphere (Rad Survey, 1955a). One sample was taken in 

a thorium area and the other was taken in a uranium area. Results are listed in units of μCi/cc. 

The system’s counting efficiency and Minimum Detectable Activity (MDA) are not indicated. 
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• Six samples were taken by the Liberty Mutual Insurance Company’s Office of Industrial Hygiene 

(two on July 6, 1955; two on August 1, 1955; and two on October 26, 1955). The samples were 

collected at a sampling rate of approximately 20 liters per minute and counted on a Model PCC-10 

Counter Scaler and Keleket Model K-281 (Rad Survey, 1955c). The samples could not be readily 

associated with a specific process area. Results are listed in units of μCi/ml. The system’s 

counting efficiency and MDA are not indicated. 

• Thirteen samples were collected in April 1957 and analyzed by HASL for gross alpha (Air Dust 

Samples, April 1954 & 1957). Only five of the samples could be associated with an identifiable 

location due to illegibility; four of the samples were from a contaminated locker room; one was 

from a thorium processing location. Results are listed in units of d/min/m3. The system’s 

counting efficiency and MDA are not indicated. 

• Twenty-eight sample results (short-lived and long-lived alpha-emitters) were reported for 14 

samples collected on July 11, 1957 by the Massachusetts Department of Labor and Industries, 

Division of Occupational Hygiene (Elkins, 1957). Fourteen of the sample results (from seven 

samples) could be associated with the thorium processing area. The samples were counted with an 

alpha scintillation counter with a reported efficiency of 24%. Results are listed in units of μCi/ml. 

The system’s MDA is not indicated. 

• Forty-two sample results (short-lived and long-lived alpha-emitters) were reported for 21 samples 

collected on May 13, 1958 by the Massachusetts Department of Labor and Industries (Pagnotto, 

1958). Sixteen of the sample results (from eight samples) could be associated with the thorium 

processing area; six of the sample results (from three samples) could be associated with the 

uranium processing area. The system’s counting efficiency and MDA are not indicated. Results 

are listed in units of μCi/ml. 

• Two samples were collected on September 9, 1958 by the Liberty Mutual Insurance Company 

(Rad Survey, 1958). One sample was taken in the thorium processing area and the other was 

taken in the uranium processing area. Samples were collected at a sampling rate of approximately 

19.8 liters per minute and counted on a Gas Flow Proportional Counter. The system’s counting 

efficiency and MDA are not indicated. Results are listed in units of μCi/ml. 

• Five samples were collected in 1962, 1963 and 1964. All five could be identified as being taken 

in a thorium area. All results are listed in units of μCi/cc; system counting efficiencies and MDAs 

are not indicated. Two samples were collected on February 2, 1962 (Rad Survey, 1962) and one 

sample was collected on February 20, 1963 (Rad Survey, 1963) by Liberty Mutual Insurance 

Company using an NMC Gas Flow Alpha Proportional Counter. Two samples were collected on 

July 24, 1964 by Liberty Mutual Insurance Company and counted for alpha activity using an 

NMC Alpha-Beta Proportional Counter, Model PC-3A (Rad Survey, 1964a). 

Area Survey Data 

Six hundred seventy-three area survey results were identified in the Norton Co. records. Of those 673 

results, 271 were taken prior to 1955 and had either unknown units (9 results) (Rad Survey, 1953-
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1954) or specified microamperes for alpha (262 results) (Gustafson, 1954). The instrument type, the 

radioactive source being measured, instrument efficiency, and MDA are not identified. 

Of the 673 results, 336 were taken in 1955. Units ranged from counts per minute (cpm), 

disintegrations per minute (dpm) to μCi/ml to unknown. In all cases, instrument efficiency and MDA 

are not identified. Of the 336 results, 33 were reported as removable contamination measurements. 

• The Norton Co. performed surveys on February 2, 1955 (Rad Survey, 1955d) and March 14, 1955 

(Benedict, 1955) using a Sampson D5 survey meter. During another survey on June 3, 1955, a 

Sampson alpha survey meter was employed and removable contamination samples were counted 

with an alpha scintillation counter (Rad Survey, 1955a). 

• The Liberty Mutual Insurance Company performed surveys on July 2 and 28, 1955 (Rad Survey, 

1955b) and October 26, 1955 (Rad Survey, 1955c), all using a Sampson alpha survey meter. 

Another survey on December 7, 1955 (McAllister, 1955) also employed a Sampson alpha survey 

meter; wipe samples were counted with a Tracerlab survey meter with an end window GM tube. 

During a November 19, 1956 survey, the Norton Co. obtained six results (Benedict, 1956). It is not 

known whether the results reflect direct survey or removable contamination. Measurement units, 

instrument efficiency, and MDA are not identified. 

During a March 8, 1957 survey, the Liberty Mutual Insurance Company obtained ten results, all of 

which were identified as removable contamination samples (McAllister, 1957). The samples were 

counted on a gas flow proportional counter. Instrument efficiency and MDA are not identified; units 

are identified as cpm. 

During a September 9, 1958 survey, the Liberty Mutual Insurance Company obtained ten results (Rad 

Survey, 1958). These removable contamination samples surveyed approximately 100 cm2

 of surface. 

Instrument type, efficiency, and MDA are not identified. Units are identified as dpm. 

In a July 26, 1961 letter of application to the AEC requesting approval to bury “waste licensed source 

material,” Norton Co. indicated that the readings from the waste ranged from 0 to 1000 counts per 

minute with several pieces reading in excess of 12,500 counts per minute (Johnson, 1961). The waste 

had been surveyed indiscriminately with a Sampson alpha meter using a 100-cm2

 window. Exterior 

surfaces of the waste barrels were monitored with a Nuclear Instrument and Chemical Corporation 

beta-gamma meter. Those readings ranged from 0.03 to 0.9 mr/hr. Instrument efficiency was not 

provided (Johnson, 1961). 

An August 10, 1962 letter of application to the Massachusetts Department of Public Health states that 

1,510 pieces of waste material had been surveyed with a Sampson Alpha Survey Model D-5 

ionization type instrument using a 100 cm2 window (Johnson, 1962). Results reported in that August 

1962 correspondence give only a maximum reading of 500 counts per minute (Johnson, 1962). The 

same document states that spectrographic analyses were performed on random waste samples, 

indicating there was less than one part per million of thorium and uranium in the body of the waste 

materials. 
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Correspondence to the Director of Environmental Health, dated October 11, 1962, indicates that 

during the burial of barrels from October 8 through 10, 1062, Norton Co. Hygiene and Safety 

monitored worker clothing contamination with a Sampson Alpha meter using a 100-cm2 window 

(Mondor, 1962). Results are not provided, with the exception of a statement saying that meter 

readings were zero (Mondor, 1962). 

 During a January 10, 1964 survey by an unknown party, 16 results were obtained (Rad Survey, 

1964b). The samples appear to have been analyzed by HASL. The samples were counted on an alpha 

counter with a geometry of 44.14% and a smear position factor of 0.81. It is not clear if the samples 

were taken by direct survey or by smear. Units are identified as dpm. 

During a July 24, 1964 survey, the Liberty Mutual Insurance Company collected 19 removable 

contamination samples, each representing approximately 100 cm2 of surface (Rad Survey, 1964a). 

These samples were counted for alpha activity using an NMC alpha-beta proportional counter. The 

efficiency and MDA are not identified. Units are identified as dpm. 

During a September 8, 1965 survey, the Norton Co. collected seven samples (Johnson, 1965). It is not 

clear if the samples were taken by direct survey or by smear. Units are identified as cpm. Instrument 

type, efficiency, and MDA are not identified. 

6.2 Available Norton Co. External Monitoring Data 

Records for Norton Co. were reviewed to identify external monitoring data. These data can take the 

form of direct readings using a survey instrument or data collected from film badges and/or 

thermoluminescent dosimeters. 

• Twelve dose rate measurements were taken by Norton Co. from September 20 to October 1, 1945 

(Norton, 1945). These results were taken with a Victoreen Glasser-Seitz Model 70 R-meter. 

Instrument efficiency and MDA are not identified. Results are reported in R/24 hours. 

• Eighteen dose rate measurements were made by Norton Co. on February 18, 1954 (Gustafson, 

1954). Instrument type, efficiency, and MDA are not identified. Results are reported in mR/hr. 

• Twenty-one dose rate measurements results were taken by the Massachusetts Department of Labor 

& Industries, Division of Occupational Hygiene on July 11, 1957 (Elkins, 1957). These results 

were collected using a Thyac survey meter. Instrument efficiency and MDA are not identified. 

Results are reported in mR/hr. 

• Twenty-four film badge results were identified for 1958 (Badge Results, 1958). The film badges, 

analyzed by Tracerlab, measured beta and gamma radiation and had a quoted MDA of 20 mR. 

While it appears that these badges were worn by individuals, this cannot be absolutely determined. 

Results are reported in mR. 

• One dose rate measurement was taken by Norton Co. on September 8, 1965 (Johnson, 1965). 

Instrument type, efficiency, and MDA are not identified. The measurement unit is mR/hr. 
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7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class as summarized in Section 7.5. 

This approach is discussed in DCAS’s SEC Petition Evaluation Internal Procedures which are 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00173 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Norton Co. Data 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1 Internal Monitoring Data Pedigree Review 

As discussed in Section 6.1, internal monitoring data are available for Norton Co. While there is no 

direct evidence that Norton Co. conducted a routine urinalysis or air monitoring program, data are 

available for the facility. 
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Available records provide thirty-one urine sample results from 1955 to 1958. Samples collected in 

1955 and 1956 were analyzed for uranium (Urinalysis, 1955; Urinalysis, 1956). The data are reported 

in handwritten entries on HASL forms. The remaining samples from 1957-1958 were analyzed for 

the thorium daughter Pb-212 to determine exposure to Th-228 (Elkins, 1957; Pagnotto, 1958). While 

records indicate that the samples were collected as part of a visit from the Massachusetts Department 

of Labor and Industries, there is no indication of who performed the analysis. The results appear in a 

typed memo from the Massachusetts Department of Labor and Industries to the Norton Co. 

There are ninety-eight air monitoring results from 1955 to 1964. Sample results prior to January 1, 

1958 (i.e., during the operational period) were collected either by the Norton Co. (Rad Survey, 

1955a), Liberty Mutual Insurance Co. (Rad Survey, 1955c), HASL (Urinalysis, 1956), or the 

Massachusetts Department of Labor and Industries (Elkins, 1957). In all situations, the data were 

either handwritten on the original analysis forms (Urinalysis, 1956) or in typed memos (Elkins, 1957; 

Rad Survey, 1955a; Rad Survey, 1955c). While there is some limited information on the type of 

counting system used to perform the analysis for each of the data sets, the MDA is never provided. 

Although limited information is available on the type of contamination being sampled (i.e., U or Th), 

the majority of data was collected in an unknown radionuclide environment. 

There are forty-nine air monitoring results for samples collected after January 1, 1958. One data set 

was collected by the Massachusetts Department of Labor and Industries (Pagnotto, 1958). Four other 

data sets were collected by Liberty Mutual Insurance Co. (Rad Survey, 1958; Rad Survey, 1962; Rad 

Survey, 1963; Rad Survey, 1964a). In all cases, the data are reported in typed memos from the 

respective organizations. While there is some limited information on the type of counting system 

used to perform the analysis for each of the data sets, the MDA is never provided. Although limited 

information is available on the type of contamination being sampled (i.e., U or Th), the majority of 

data was collected in an unknown radionuclide environment. 

NIOSH has identified 673 survey results from 1954 to 1965. The 1954 data documentation does not 

identify who collected the results; the results are handwritten on lined paper and there is no 

information on instrumentation or the type of radionuclide environment (Rad Survey, 1953-1954;

Gustafson, 1954). Approximately half of all survey data (336 of 673 results) was generated in 1955. 

Three sets of data were collected by the Norton Co. (Rad Survey, 1955d; Rad Survey, 1955a;

Benedict, 1955). One of these data sets contains removable contamination (wipe) survey data (Rad 

Survey, 1955a). In all three records, the data are reported in a typed memo. Three other data sets 

were collected in 1955 by the Liberty Mutual Insurance Company (Rad Survey, 1955b; Rad Survey, 

1955c; McAllister, 1955). One of these data sets contains removable contamination (wipe) survey 

data (McAllister, 1955). In all three records, the data are presented in a typed memo. For all of the 

data sets above, there is varying information on the counting systems used, but no mention of the 

MDA. 

Survey data were collected by the Norton Co. in 1956 (Benedict, 1956) and by the Liberty Mutual 

Insurance Co. in 1957 (McAllister, 1957). The information in the 1957 data set indicates removable 

contamination survey results. The data above were reported in typed memos; there is no information 

on the MDA or counter efficiency. 

Data collected after the AWE operational period are very limited. Ten wipe sample results were 

recorded in 1958 by the Liberty Mutual Insurance Co. (Rad Survey, 1958). The results are reported in 
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a typed memo; no information on instrument type, efficiency, or MDA is provided. Sixteen results 

were identified for 1964 from an unknown party (Rad Survey, 1964b). Data were reported in a copy 

of what appears to be a logbook page with handwritten results. It is clear that a standard was used for 

efficiency determination; a background sample was also recorded. The samples appear to have been 

analyzed by HASL. Nineteen wipe data results were collected by the Liberty Mutual Insurance 

Company and reported in a typed memo format (Rad Survey, 1964a). No information on the counting 

system or MDA is provided. Seven wipe results were collected in 1965 by the Norton Co. (Johnson, 

1965). The results are reported in a typed memo with no information on the counting system, 

efficiency, or MDA. 

A substantial volume of data was collected in 1997. A four-volume report written about the site 

(Radiation Safety Associates, 1997a; Radiation Safety Associates, 1997b; Radiation Safety 

Associates, 1997c; Radiation Safety Associates, 1997d) indicates that Decontamination and 

Decommissioning (D&D) activities occurred in 1968. The report also states that “...some of the 

remediation practices used, are not currently appropriate for residual natural uranium or natural 

thorium.” As a result, additional remediation activities occurred in 1996. 

While any single set of data discussed above may or may not be sufficient to develop a dose 

reconstruction methodology for the residual radiation period under evaluation, a dataset that combines 

these multiple data sets is sufficient to allow NIOSH to develop a workable methodology. All data 

used by NIOSH were taken directly from scanned copies of actual hard-copy data sheets and reports. 

7.1.2 External Monitoring Data Pedigree Review 

During the review of the Norton Co. records in the SRDB, NIOSH identified external monitoring 

data. These data were from real-time monitoring with a hand-held external dose survey meter and 

from film badge results that integrated exposure over time. 

Real-time monitoring data collected by the Norton Co. were located for 1945 (Norton, 1945). Results 

are reported in a typed memo from that time period. Although the instrument type is identified, the 

instrument efficiency and the MDA are not provided. 

Real-time monitoring data collected by the Norton Co. were located for 1954 (Gustafson, 1954). 

Results are presented in a typed memo from that time period. Instrument type, efficiency, and MDA 

are not identified. 

Data collected by the Massachusetts Department of Labor and Industries, Division of Occupational 

Hygiene, were located for 1957 (Elkins, 1957). Results are presented in a typed memo from that time 

period. Although the instrument type is identified, the instrument efficiency and the MDA are not 

provided. 

Records included film badge data collected in 1958 (Badge Results, 1958). Results were supplied by 

Tracerlab and are reported in a typed Tracerlab memo. Gamma exposures were recorded, and where 

beta exposures occurred, beta dose was also recorded. The Minimum Measured Dose as identified in 

the report is 20 mR. 
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Survey data of waste barrels and clothing obtained during the clean-up period from January 1, 1958 

through October 10, 1962, were reported in counts per minute and mr/hr on typed Norton Co. memos 

(Mondor, 1962; Johnson, 1962; Johnson, 1961). 

One record identified an external dose range recorded by the Norton Co. in 1965 (Johnson, 1965). 

Results are presented in a typed memo from that time period. Instrument type, efficiency, and MDA 

are not provided. 

The external monitoring data listed above are sufficient to allow NIOSH to develop a dose 

reconstruction methodology for the Norton Co. residual radiation period under evaluation. All data 

used by NIOSH were taken directly from scanned copies of actual hard-copy data sheets and reports. 

7.2 Evaluation of Bounding Internal Radiation Doses at Norton Co. 

The principal source of internal radiation doses for members of the residual radiation period under 

evaluation would have been uranium and thorium from the tear-down, clean-up, and disposal of the 

contaminated equipment and other materials used during the operational period as well as 

re-suspension of contamination. The following subsections address the ability to bound internal 

doses, methods for bounding doses, and the feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Residual Radiation Period Internal Doses 

The following subsections summarize the extent and limitations of information available for 

reconstructing the internal doses of members of the class under evaluation. 

7.2.1.1 Urinalysis Information and Available Data 

Urinalysis data are not available for the residual radiation period. 

7.2.1.2 Airborne Levels

A limited amount of air dust results for uranium and thorium were taken during the AWE operational 

period (Air Dust Samples, April 1954 & 1957; McAllister, 1962; Elkins, 1957; Elkins, 1958; 

Pagnotto, 1958; Rad Survey, 1955a; Rad Survey, 1955c; Rad Survey, 1958). NIOSH has also 

obtained limited air monitoring results for samples collected during the residual radiation period (Rad 

Survey, 1963; Rad Survey, 1964a). However, these latter results represent monitoring of commercial 

operations (Personal Communication, 2010a) and are not considered for the feasibility of bounding 

internal radiation doses from thoria. 

Short-lived and long-lived alpha air monitoring data collected by the Massachusetts Department of 

Labor and Industries on May 13, 1958 (Pagnotto, 1958) are useful in determining the feasibility of 

bounding internal radiation doses from thorium and thoron. 
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7.2.2 Methods for Bounding Residual Radiation Period Internal Dose at Norton Co. 

NIOSH does not have adequate internal monitoring or workplace monitoring data to bound doses that 

were potentially received during the dismantling, clean-up, packaging, and burial of AWE materials 

and contamination. While NIOSH does have air monitor data obtained during the AWE operations 

period that can be used to bound doses in the residual period following the burial which culminated on 

October 10, 1962, those data cannot be assumed to bound all radioactive contamination and 

radiological contamination levels that could have arisen from the dismantling, clean-up, packaging 

and burial processes which were documented to have generated dust. 

In order to determine the feasibility of bounding potential internal doses received from exposures to 

residual radiation received after the burial of AWE materials, NIOSH evaluated air monitoring data in 

the form of long-lived gross-alpha results obtained on May 13, 1958 (reported on May 28, 1958) by 

the Massachusetts Department of Labor and Industries (Pagnotto, 1958) to derive the air concentration 

starting on October 11, 1962 through the end of the residual radiation period, October 31, 2009. The 

average of the long-lived alpha results was calculated from the data shown in Table 7-1 to estimate the 

starting air concentration (4.662 dpm/m3

) on October 11, 1962. 

Table 7-1: Air Monitoring Results, Long-Lived Alpha Emitters 

Sample 

Number 

Time 

Sampling 

Completed 

(hours) 

Location 

Long-Lived 

Alpha Emmiters 

(uCi/mL) 

Thorium Air 

Concentration 

(dpm/m3) 

1M 9.2 End of hood - thoria area 4E-13 - 

7M 2.5 End of hood - thoria area 4E-13 - 

13 2.5 End of hood - thoria area 2E-12 - 

5M 1.15 Thoria processing area 2E-12 - 

3 10 General area on bench 2E-12 - 

7 11.2 Hood - thoria area 1E-12 - 

11 2 Bench near thoria area 2E-12 - 

14 2.5 By glass cutting wheel 7E-12 - 

Average - thoria area samples 2.1E-12 4.662 

Average daily intake rates for inhalation and ingestion were calculated based on an inhalation rate of 

1.2 m3

/hr, 8-hour workday, and 250 workdays per year, resulting in a value of 30.654 dpm/day for the 

period from October 11, 1962 through December 31, 1963. Intake rates for the following years 

through October 31, 2009 have been adjusted due to source term depletion per guidance in ORAUTOTIB-0070. The air monitoring results are reported in units of gross alpha and are not isotopicspecific; therefore, the most claimant-favorable radionuclide and solubility class will be assigned by 

NIOSH. The Norton Co. processed both uranium oxide and thoria. Because Norton Co. processed 

both uranium and thorium oxides, uranium can be assumed to be U-234 (Types M and S) and thorium 

can be assumed to be Th-232 (Types M and S). 
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Table 7-2: Intake Rates for Uranium or Thorium 

Applicable Period ORAUT-OTIB-0070 

Adjustment 

Inhalation 

(dpm/day) 

Ingestion 

(dpm/day) Distribution 

01/1958 - 10/10/1962 not feasible not feasible not feasible N/A 

10/11/1962 - 12/31/1963 1 30.654 0.747 Constant 

01/01/1964 - 12/31/1964 0.03 0.920 0.022 Constant 

1965 and later 0.0007 0.021 0.001 Constant 

NIOSH does not consider radon as an exposure source, as Norton Co. only had uranium metals and 

associated dust onsite. NIOSH has identified thoron monitoring data in the form of short-lived thoria 

results obtained on May 13, 1958 (reported on May 28, 1958) (Pagnotto, 1958). NIOSH used the 

reported average short-lived values as actual values of thoron, as provided in Table 7-3 to calculate 

the intake rate of thoron from the end of the burial operation through December 31, 1963. Working 

level (WL) and working level months (WLM) were calculated for each result and for the average of 

the reported short-lived results.

Table 7-3: Air Monitoring Results, Short-Lived Alpha Emitters 

Sample 

Number 

Time Sampling 

Completed 

(hours) 

Location 

Short-Lived 

Alpha Emmiters 

(uCi/mL) 

Thoron 

(WL) 

Thoron 

(WLM) 

1M 9.2 End of hood - thoria area 3.3E-11 0.00440 0.0518 

7M 2.5 End of hood - thoria area 4E-11 0.00533 0.0627 

13 2.5 End of hood - thoria area 3.6E-11 0.00480 0.0565 

5M 1.15 Thoria processing area 4.2E-11 0.00560 0.0659 

3 10 General area on bench 5.2E-11 0.00693 0.0816 

7 11.2 Hood - thoria area 4.1E-11 0.00547 0.0643 

11 2 Bench near thoria area 2.26E-10 0.03013 0.3545 

14 2.5 By glass cutting wheel 3.1E-11 0.00413 0.0486 

Average - thoria area samples 6.2625E-11 0.00835 0.0982 

Intake rates for the following years have been adjusted due to source term depletion per guidance in 

ORAUT-OTIB-0070. Thoron intake rates for the Norton Co. residual radiation period are provided in 

Table 7-4. 

Table 7-4: Intake Rates for Thoron 

Applicable Period ORAUT-OTIB-0070 

Adjustment 

Thoron 

(WLM)) Distribution 

01/1958 - 10/10/1962 not feasible not feasible N/A 

10/11/1962 - 12/31/1963 1 0.0982 Constant 

01/01/1964 - 12/31/1964 0.03 0.0029 Constant 

1965 and later 0.0007 0.0001 Constant 
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7.2.3 Internal Dose Reconstruction Feasibility Conclusion 

As presented in Section 5.1, between October 8 and October 10, 1962, Norton Co. employees 

transported clean-up wastes to a portion of the Norton Co. landfill and buried the wastes. NIOSH has 

insufficient data to bound potential internal exposures during these waste burial operations. NIOSH 

therefore concludes that reconstruction of potential internal radiation doses resulting from exposures 

to residual uranium, thorium, and thoron at the Norton Co. is not feasible for the period from January 

1, 1958 through October 10, 1962. NIOSH concludes that reconstruction of potential internal 

radiation doses resulting from exposures to residual uranium and thoron at the Norton Co. is feasible 

for the period from October 11, 1962 through October 31, 2009 (the period after the Norton Co. waste 

was buried). 

NIOSH has determined that reconstruction of internal dose received during Norton Co. 

decontamination activities from January 1, 1958 through October 10, 1962, is not feasible. Although 

NIOSH found that it may not be possible to completely reconstruct internal radiation doses for all 

workers for the period from January 1, 1958 through October 10, 1962, NIOSH intends to use any 

available internal monitoring data that may become available for an individual claim (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures). Dose reconstructions 

for individuals employed at Norton Co. during the period from January 1, 1958 through October 10, 

1962, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 

7.3 Evaluation of Bounding External Radiation Doses at Norton Co. 

The principal source of external radiation doses for members of the evaluated class was direct 

radiation from surface contamination as well as exposure resulting from submersion in air 

contaminated with re-suspended residual uranium and thorium. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding Residual Radiation Period External Doses 

Workers involved in the decontamination activities were monitored by TracerLab film badges 

(Personal Communication, 2010a); however, NIOSH has not identified any external dosimeter results 

obtained during the residual radiation period. Personnel were potentially subjected to direct external 

exposure from surface radioactive contamination and to submersion in contaminated air as a result of 

re-suspension of surface contamination. Using the air contamination data obtained during the 

operational period and the methods in Battelle-TBD-6000, there are sufficient data and methods to 

support bounding the external dose during the residual radiation period from October 11, 1962 

through October 31, 2009. 

7.3.2 Norton Co. Occupational X-Ray Examinations 

Doses received from occupational medical X-rays are not considered as part of the source term for the 

residual radiation period; therefore, medical X-rays were not evaluated. 
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7.3.3 Methods for Bounding Residual Radiation Period External Dose at Norton Co. 

In order to determine the feasibility of bounding potential external doses received from exposures to 

residual radiation, NIOSH evaluated air monitoring data obtained during the operations period. The 

95th percentile of the gross alpha air dust results was calculated to estimate the highest contamination 

levels present after the AWE materials had been buried starting on October 11, 1962. It is assumed 

that the material deposited on the floor with a deposition velocity of 0.00075 m/s from October 11, 

1962 through December 31, 1963. This results in a maximum contamination level of 1.83×106

dpm/m2

. Using these assumptions, daily doses can be calculated based on the maximizing potential 

radionuclide. The external doses are from penetrating photons with energies between 30 and 250 keV 

and electron energy range of >15 keV for penetrating exposures. Table 7-5 shows the external dose 

rates for the residual radiation period adjusted for source term depletion per the guidance provided in 

ORAUT-OTIB-0070 and Battelle-TBD-6000. 

NIOSH has identified no personnel or workplace monitoring data that can be used to quantify such 

contamination or accurately bound external doses potentially received during the period from January 

1, 1958 through October 10, 1962, during the clean-up and burial operations. Therefore, NIOSH finds 

that it is not feasible to reconstruct doses received from potential external exposures to radioactive 

contamination during the period of January 1, 1958 through October 10, 1962. 

Table 7-5: External Dose Rates for the Residual Radiation Period 

Applicable Period ORAUT-OTIB-0070 

Adjustment Gamma (rem/year) Beta  (rem/year) 

01/1958 - 10/10/1962 not feasible not feasible not feasible 

11/11/1962 - 12/1963 1 0.026 0.233 

01/1964 - 12/1964 0.03 0.001 0.007 

1965 onward 0.0007 <0.001 <0.001 

7.3.4 External Dose Reconstruction Feasibility Conclusion 

NIOSH has not identified any external dosimeter results obtained during the residual radiation period, 

and consequently has insufficient external monitoring data to bound potential external exposures 

during waste burial operations through October 10, 1962. NIOSH therefore concludes that 

reconstruction of potential external radiation doses resulting from exposures to residual contamination 

at the Norton Co. is not feasible for the period from January 1, 1958 through October 10, 1962. 

NIOSH concludes that reconstruction of potential external radiation doses resulting from exposures to 

residual uranium and thorium at Norton Co. is feasible for the period from October 11, 1962 through 

October 31, 2009 (the period after the Norton Co. waste was buried). 

NIOSH has determined that reconstruction of external dose received during Norton Co. 

decontamination activities from January 1, 1958 through October 10, 1962, is not feasible. Although 

NIOSH found that it may not be possible to completely reconstruct external radiation doses for all 

workers for the period from January 1, 1958 through October 10, 1962, NIOSH intends to use any 

available external monitoring data that may become available for an individual claim (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures). Dose reconstructions 
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for individuals employed at the Norton Co. during the period from January 1, 1958 through October 

10, 1962, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 

7.4 Evaluation of Petition Basis for SEC-00173 

The following subsections evaluate the assertions made on behalf of petition SEC-00173 for the 

Norton Co. 

7.4.1 Petition Basis 

SEC-00173: The petitioner selected as the petition basis that the records relating to some types of 

radiation exposures and doses incurred by the class, or relating to certain periods of time, certain 

operations, or certain exposure incidents involving the class, have been lost, falsified, or destroyed, or 

that there is no such information (Petition, 2010).

NIOSH has concluded that it is not feasible to reconstruct doses received from potential exposures to 

residual contamination for Norton Co. workers involved in the clean-up and burial of AWE materials 

and equipment, as discussed in Sections 7.2 and 7.3. 

7.4.2 Waste Disposal Area on I-190 Ramp 

SEC-00173: In the petition for SEC-00173, the petitioner included information about Norton Co. 

waste that had been buried on land that eventually was used to build a ramp to Interstate I-190 

(Petition, 2010).

In Section 5.1, NIOSH documented that during the residual radiation period activities in 1962, 

materials and equipment were buried in a portion of the Norton Co. landfill located on Norton Co. 

property. NIOSH further learned that some of that landfill was transferred to the State of 

Massachusetts for highway construction (Personal Communication, 2010a). NIOSH has concluded 

that it is not feasible to reconstruct doses received from potential exposures to residual contamination 

for Norton Co. workers involved in the clean-up and burial of AWE materials and equipment, as 

discussed in Sections 7.2 and 7.3. 

7.5 Summary of Feasibility Findings for Petition SEC-00173 

This report evaluates the feasibility for completing dose reconstructions for all atomic weapons 

employees who worked in any building or area at the facility owned by the Norton Co. during the 

period from January 1, 1958 through October 31, 2009. NIOSH found that the available monitoring 

records, process descriptions and source term data available are sufficient to complete dose 

reconstructions for the evaluated class of employees for the period from October 11, 1962 through 

October 31, 2009. However, NIOSH also found that it lacks sufficient monitoring records, process 

descriptions, and source term data to complete dose reconstructions for the evaluated class of 

employees for the period from January 1, 1958 through October 10, 1962. 
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Table 7-6 summarizes the results of the feasibility findings at Norton Co. for each exposure source 

during the residual radiation period from January 1, 1958 through October 31, 2009. 

Table 7-6: Summary of Feasibility Findings for SEC-00173 

January 1, 1958 through October 31, 2009 (residual radiation period)

Source of Exposure 

Jan. 1, 1958 - October 10, 1962 October 11, 1962 - Oct. 31, 2009 

Reconstruction 

Feasible 

Reconstruction 

Not Feasible 

Reconstruction 

Feasible 

Reconstruction 

Not Feasible 

Internal X X 

Uranium X X 

Thorium X X 

Thoron X X 

External X X 

Gamma X X 

Beta X X 

Neutron N/A 

Occupational Medical X-ray N/A 

As of December 19, 2010, a total of 56 claims have been submitted to NIOSH for individuals who 

worked at Norton Co. and are covered by the class definition evaluated in this report. Dose 

reconstructions have been completed for eighteen individuals (~32%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00173 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has obtained gross alpha air monitoring results collected at the Norton Co. near the end of the 

AWE operations period and during the residual radiation period. Using those data and the guidance in 

ORAUT-OTIB-0070, NIOSH can bound the internal doses potentially received from exposures to 
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residual uranium and thoria for the period from October 11, 1962 through October 31, 2009. The 

gross alpha air contamination data from the operational period and the methods described in BattelleTBD-6000 allow NIOSH to bound external doses from residual uranium and thoria for the period 

from October 11, 1962 through October 31, 2009. NIOSH’s evaluation determined that it is feasible 

to estimate radiation dose for members of the NIOSH-evaluated class for the period from October 11, 

1962 through October 31, 2009, with sufficient accuracy based on the sum of information from 

available resources. Modification of the class definition regarding health endangerment and minimum 

required employment periods, therefore, is not required for the October 11, 1962 through October 31, 

2009 period. However, NIOSH’s evaluation determined that it is not feasible to estimate radiation 

dose for members of the NIOSH-evaluated class for the period from January 1, 1958 through October 

10, 1962, with sufficient accuracy. Modification of the class definition regarding health 

endangerment and minimum required employment periods, therefore, is required for the January 1, 

1958 through October 10, 1962 period. 

9.0 Class Conclusion for Petition SEC-00173 

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class to be added to the SEC includes all atomic weapons employees who worked in any 

building or area at the facility owned by the Norton Co. (or a subsequent owner) in Worcester, 

Massachusetts, during the period from January 1, 1958 through October 10, 1962, for a number of 

work days aggregating at least 250 work days, occurring either solely under this employment or in 

combination with work days within the parameters established for one or more other classes of 

employees included in the Special Exposure Cohort. NIOSH has determined that decontamination 

and decommissioning activities were conducted at Norton Co. from January 1, 1958 through October 

10, 1962, for which NIOSH lacks sufficient source term and monitoring data to bound doses 

potentially received from exposures during that work. NIOSH finds that it does have sufficient data to 

bound doses for the period from October 11, 1962 through October 31, 2009. 

 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00173. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 
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standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 
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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

Air Dust Samples, April 1954 & 1957, Air Dust Sample for Norton Co., U. S. Atomic Energy 

Commission, Health and Safety Division; various dates in April 1954 and April 1957; SRDB Ref ID: 

10412, pdf pp. 1-2, 5, 7-12 

Badge Results, 1958, Film Badge Radiation Dose Reports for the Weeks of February 3, 1958 and 

March 3, 1958; processed by Tracerlab Inc.; reports dated March and April 1958; SRDB Ref ID: 

32673 

Bate, 1953, Fabrication of Urania Crucibles by Norton Company for Argonne, correspondence to D. 

P. Rudolph; G. A. Bate, U.S. Atomic Energy Commission; December 1953; SRDB Ref ID: 29778 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium and Thorium 

Metals, Rev. F0; Battelle Team Dose Reconstruction Project for NIOSH; December 13, 2006; SRDB 

Ref ID: 30671 

Benedict, 1955, Industrial Building Inspection for December 5, 1955, memorandum to the Medical 

Director; K. T. Benedict; December 5, 1955; SRDB Ref ID: 32682, p. 3 

Benedict, 1956, Industrial Building Inspection of Worcesters’ Hands Prior to Coffee Period, 

November 19, 1956, correspondence to the Medical Director; K. T. Benedict; November 20, 1956; 

SRDB Ref ID: 32684 

Braiden, 1954, SF Material Located at the Norton Company, correspondence to V. Vespe 

(Accountability Representative, Chicago Operations Office); S. J. Braiden (Acting Chief, SF 

Accountability Branch, New York Operations Office); June 4, 1954; SRDB Ref ID: 10397, pdf p. 50 
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Daume, 1947, Various Internal AEC Memos Concerning Beryllium Cylinder Orders; W. B. Daume 

and one unidentified author; various dates in 1947; SRDB Ref ID: 31645, pdf pp. 6, 12, 27, 32 

DOE, unknown date, Facility Profile for Norton Co.; U.S. Department of Energy (DOE), 

Environmental Management; unknown date; SRDB Ref ID: 10397, pdf p. 52 

Elkins, 1957, Air Sample, Exposure, and Urinalysis Results Collected July 11, 1957, correspondence 

to Karl T. Benedict; Harvey B. Elkins; July 30, 1957; SRDB Ref ID: 78702 

Elkins, 1958, Thoria Handling and Associated Calculations, correspondence to Karl T. Benedict; 

Harvey B. Elkins; June 3, 1958; SRDB Ref ID: 78700, pdf p. 2 

Geo Survey, 1949, Select Pages of the 1949 Version of the Minerals Yearbook, listing of sites 

currently using compounds of thorium (including Norton Co.); Annual publication by the U.S. 

Geological Survey (U.S. Bureau of Mines); 1949 Publication; SRDB Ref ID: 42461 

Gustafson, 1954, Radiation Count in Special Products Area, memorandum for Special Products 

Section; C. H. Gustafson; February 18, 1954; SRDB Ref ID: 32680 

Harris, 1954, Operational Health Controls for Beryllium, Thorium, and Uranium Operations, 

correspondence to Karl T. Benedict, Norton Co.; William B. Harris, U.S. Atomic Energy Commission 

Health and Safety Laboratory; April 7, 1954; SRDB Ref ID: 10397, pdf pp. 13-14 

Henson, 1954a, Your Inquiry No. WH-393, Uranium Oxide Crucibles, correspondence to W. L. Hurst, 

Westinghouse Electric Corporation; W. H. Henson, Norton Company Refractories Division; March 2, 

1954; SRDB Ref ID: 59533 

Henson, 1954b, Thoria Cylinders, correspondence to David Masket, U.S. Atomic Energy 

Commission; W. H. Henson, Norton Company Refractories Division; April 29, 1954; SRDB Ref ID: 

10397, pdf pp. 9-11 

Inventory, various dates, Various AEC Memos Regarding Inventories of Uranium at the Norton 

Company, Worcester, MA, Site; various AEC personnel; various dates; SRDB Ref ID 10397, pdf pp. 

38-39, 50, 64 

Johnson, 1961, Waste Disposal, correspondence to the AEC Compliance Division; R. S. Johnson; July 

26, 1961; SRDB Ref ID: 90731 

Johnson, 1962, Waste Material Slightly Contaminated with Radioactive Material, correspondence to 

the Massachusetts Department of Public Health; R. S. Johnson; August 10, 1962; SRDB Ref ID: 

90729 
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Johnson, 1965, Radiation Survey on September 8, 1965, correspondence to the Plant Protection and 

Safety Department; R. S. Johnson; October 15, 1965; SRDB Ref ID: 32685 

McAllister, 1955, Atmospheric and Wipe Sample Results, correspondence to Karl T. Benedict; R. G. 

McAllister; December 27, 1955; SRDB Ref ID: 32676 

McAllister, 1957, Wipe Sample Results from Enriched Area, correspondence to Karl T. Benedict; R. 

G. McAllister; March 22, 1957; SRDB Ref ID: 32672 

McAllister, 1962, Effluent Air Sample Results for the Norton Co., correspondence to Richard S. 

Johnson; R. G. McAllister, Liberty Mutual Insurance Company; February 19, 1962; SRDB Ref ID: 

32669 

Mondor, 1962, Dumping of Radioactive Waste at Norton Co. Dump, correspondence to John F. Smith, 

Director of Environmental Health; John H. Mondor; October 11, 1962; SRDB Ref ID: 90728 

NIOSH, 2009, SEC Petition Evaluation Report for Petition SEC-00148, Norton Co.; National Institute 

for Occupational Safety and Health (NIOSH); July 7, 2009; SRDB Ref ID: 82752 

Norton, 1945, Thorium Oxide Radioactivity Measurements; Norton Co.; October 2, 1945; SRDB Ref 

ID: 78703 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities, Rev. 00; March 10, 2008; SRDB Ref ID: 41603 

Pagnotto, 1958, Study of Air Samples and Urinalysis Data (From May 13, 1958 Visit) in Regards to 

Thoria Handling, correspondence to Harvey Elkins; Leonard Pagnotto and Harold Bavley; May 28, 

1958; SRDB Ref ID: 78700, pdf pp. 3-5 

Personal Communication, 2010a, Personal Communication with Former Norton Co. Industrial Health 

Care Worker; Telephone interview; September 14, 2010; SRDB Ref ID: 88131 

Personal Communication, 2010b, Personal Communication with Former Norton Co. 

Machinist/Foreman; Telephone interview; September 14, 2010; SRDB Ref ID: 88133 

Personal Communication, 2010c, Personal Communication with Norton Co. Communications 

Specialist; Telephone interview; September 21, 2010; SRDB Ref ID: 90292 
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Petition, 2010, SEC Petition and Supporting Documents for Norton Co., received by NIOSH on May 

17, 2010; OSA Ref ID: 11643

Rad Handbook, 1998, Handbook of Health Physics and Radiological Health, 3rd Edition, B. Shleien, 

L. A. Slaback, Jr., B. K. Birky, editors; 1998; SRDB Ref ID: 22737 (commonly available from public 

resources) 

Rad Survey, 1953-1954, Results for 1953-1954 Area and Personnel Radiation Surveys; data capture 

sheet identifies date as 1953-1954; SRDB Ref ID: 32678 

Rad Survey, 1955a, Results for June 3, 1955 Thorium-Uranium Survey; report written by R. G. 

Gallaghar and R. G. McAllister; written after June 3, 1955; SRDB Ref ID: 78720, pdf pp. 4-8 

Rad Survey, 1955b, Results for July 2 and July 28, 1955 Thoria and Urania Radiation Survey; report 

written by R. G. McAllister; August 12, 1955; SRDB Ref ID: 78721 

Rad Survey, 1955c, Results for July 6, August 1, and October 26, 1955 Thoria and Urania Radiation 

Survey; report written by R. G. McAllister; November 16, 1955; SRDB Ref ID: 78725 

Rad Survey, 1955d, Results for February 2, 1955 Radiation Survey; survey conducted by Karl T. 

Benedict; February 2, 1955; SRDB Ref ID: 32664 

Rad Survey, 1958, Results for September 9, 1958 Thoria and Urania Radiation Survey; report written 

by Ralph Renzi; October 20, 1958; SRDB Ref ID: 78724 

Rad Survey, 1962, Results for February 2, 1962 Thoria-Urania Section in Special Radiation Survey; 

survey conducted by Liberty Mutual; report written by R. S. Johnson on March 2, 1962; SRDB Ref 

ID: 32669 

Rad Survey, 1963, Results for February 20, 1963 Thoria in Air Radiation Survey; survey conducted 

by Liberty Mutual; report written by R. S. Johnson on March 5, 1963; SRDB Ref ID: 32687

Rad Survey, 1964a, Results for July 24, 1964 Thoria in Air Radiation Survey; survey conducted by 

Liberty Mutual; August 19, 1964; SRDB Ref ID: 78722 

Rad Survey, 1964b, Alpha and Beta Results for Samples taken January 10, 1964; report written on 

January 17, 1964; SRDB Ref ID: 82508, pdf pp. 10-11 

Radiation Safety Associates, 1997a, Final Radiological Status Report for Building 112 SaintGobain/Norton, Volume I; Radiation Safety Associates, Inc.; February 4, 1997; SRDB Ref ID: 78714 

Radiation Safety Associates, 1997b, Final Radiological Status Report for Building 112 SaintGobain/Norton, Volume II; Radiation Safety Associates, Inc.; February 4, 1997; SRDB Ref ID: 78716 
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Radiation Safety Associates, 1997c, Final Radiological Status Report for Building 112 SaintGobain/Norton, Volume III; Radiation Safety Associates, Inc.; February 4, 1997; SRDB Ref ID: 

78717 

Radiation Safety Associates, 1997d, Final Radiological Status Report for Building 112 SaintGobain/Norton, Volume IV; Radiation Safety Associates, Inc.; February 4, 1997; SRDB Ref ID: 

78718 

Randall, 1947, A Survey of the Beryllium Problem, memo to files; Raymond V. Randall; May 22, 

1947; SRDB Ref ID: 6283, pdf pp. 1-11 

Rudolph, 1953, Fabrication of Urania Crucibles by Norton Company for Argonne, correspondence to 

G. A. Bate, AEC New York Operations Office; D. P. Rudolph, AEC Chicago Operations Office; 

November 17, 1953; SRDB Ref ID: 10397, pdf p. 57 

Unidentified author, 1947, Memo Concerning Requisition 12297, correspondence to Walter P. Laber; 

unidentified author; May 12, 1947; SRDB Ref ID: 11348, pdf p. 8 

Urinalysis, 1955, Uranium Urinalysis Results for Five Employees; reported on June 22, 1955; SRDB 

Ref ID: 78720, pdf pp. 2-3 

Urinalysis, 1956, “Monday Morning” Urine Sample Results for Norton Co., Worcester, Mass.; 

reported on January 22, 1956; SRDB Ref ID: 9677, pdf p. 41; and SRDB Ref ID: 10412, pdf p. 3 
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SEC-00173 01-24-2011 

Attachment One: Data Capture Synopsis 

Table A1-1: Summary of Holdings in the SRDB for Norton Co. 

Data Capture Information Data Capture Description C

Primary Site/Company Name: Norton Co.; BE 

1944-1956; AWE 1945-1957; Residual Radiation 1958-July 2006 Other Site Names:

St. Gobain (Successor): [Name, title, and contact information redacted] 

Tracer Lab Inc. film badge radiation dosage report, various survey results, assessment of thorium exposure due to grinding of thoriated tungsten electrodes, state department of labor and industries division of occupational hygiene site visit, final radiological status report, and industrial hygiene surveys. Note: Awaiting final response from [Name and company name redacted] who provided monitoring service for Norton Company. 

02/0OPE

State Contacted: [Name, title, and contact information redacted]; [Name, title, and contact information redacted]

No relevant data identified. 08/3

DOE Germantown Elimination and security information, thoria, heavy oxide, uranium and 

thorium inventory, radiation survey after thorium oxide fusion, procedures and policies, exposure data, and hazards and safety information. 

03/1

DOE Hanford Journal of Industrial Hygiene and Toxicology article on lung cancer 

hazards. Note: Awaiting results of data search request. 

11/1OPE

DOE Legacy Management - Grand Junction Office 

FUSRAP investigation, urinalysis and air dust samples, fusions of uranium and thorium oxides, progress reports, MSA contract obligations 1946, and uranium oxide refractory and crucibles. 

06/1

DOE Legacy Management - MoundView (Fernald Holdings, includes Fernald Legal Database) 

Thorium production, engineering and development through 1954, trip report for Los Alamos Scientific Laboratory, ORNL purchase of fused thoria and crude material, fabrications of urania crucibles by Norton Company for Argonne, handling of uranium oxide, established maximum allowable concentration for airborne uranium, reduction of Ra-226 and Ra228 in plant effluents, and NLO/Norton AEC contract information. 

05/2

DOL/Paragon Weekly and monthly reports and a request for special material. 01/0Environmental Measurements Laboratory (EML) / Health and Safety Laboratory (HASL) 

Site visit reports, 1953 annual report, and thorium sampling and storage information. 

03/0

Internet - Comprehensive Epidemiologic Data Resource (CEDR) 

No relevant data identified. 06/2

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SEC-00173 01-24-2011 

Table A1-1: Summary of Holdings in the SRDB for Norton Co. 

Data Capture Information Data Capture Description 

C

Internet - DOE Hanford Declassified Document Retrieval System (DDRS) 

No relevant data identified. 06/2

Internet - DOE Legacy Management Considered Sites 

Tonawanda area report and AEC source material license. Note: One document added by site association. 

06/2

Internet - DOE OpenNet Historical report and monthly status and progress reports. 06/2Internet - DOE OSTI Energy Citations No relevant data identified. 06/2Internet - DOE OSTI Information Bridge Pacific Northwest National Laboratory activities report. 06/2Internet - Google Fusion process for production of stoichiometric UO2, improvements in or 

relating to a process for the preparation of uranium dioxide, information regarding license number STB-00770, process for the extraction of relatively pure thorium, process of making nuclear fuel element, and weekly information reports. Note: Two documents added by site association. 

06/2

Internet - HP Journal No relevant data identified. 10/0Internet - Journal of Occupational and Environmental Health 

No relevant data identified. 10/0

Internet - National Academies Press (NAP) No relevant data identified. 06/2Internet - National Nuclear Security Administration (NNSA) - Nevada Site Office 

No relevant data identified. 06/2

Internet - NRC Agencywide Document Access and Management (ADAMS) 

NRC FUSRAP sites review. Note: One document added by site association. 06/2

Internet - US Army Corps of Engineers No relevant data identified. 06/2Internet - Washington State University (U.S. Transuranium and Uranium Registries) 

No relevant data identified. 06/2

NARA - Atlanta Trip report and Norton Company information. 02/2NARA - College Park Beryllium issues at Norton Company, personal notes, and a health hazard 

survey. 

07/1

Oak Ridge National Laboratory Health hazards information and brown and black oxide at Norton. 07/0ORAU Team Confirmation of the Radiation Control Program of the Massachusetts 

Department of Public Health and documented communications. 

01/2

Unknown Air dust, breath, and water samples, urine sample results, multiple site 

historical information and thorium procurement and investigations. 

Unk

Total 

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SEC-00173 01-24-2011 

Table A1-2: Database Searches for Norton Co. 

Database/Source Keywords 

NOTE: Database search terms employed for each of the databases listed below are available 

in the Excel file called “Data Capture Synopsis for Norton Co.” 

DOE CEDR http://cedr.lbl.gov/ COMPLETED 06/24/2010 

See note above 

DOE Hanford DDRS http://www2.hanford.gov/declass/ COMPLETED 06/24/2010 

See note above 

DOE Legacy Management Considered Sites http://csd.lm.doe.gov/ COMPLETED 06/24/2010 

See note above 

DOE OpenNet http://www.osti.gov/opennet/advancedsearch.jsp COMPLETED 06/24/2010 

See note above 

DOE OSTI Energy Citations http://www.osti.gov/energycitations/ COMPLETED 06/24/2010 

See note above 

DOE OSTI Information Bridge http://www.osti.gov/bridge/advancedsearch.jsp COMPLETED 06/24/2010 

See note above 

Google http://www.google.com COMPLETED 06/22/2010 

See note above 5

HP Journal http://journals.lww.com/healthphysics/pages/default.aspx COMPLETED 10/04/2010 

See note above 

Journal of Occupational and Environmental Health http://www.ijoeh.com/index.php/ijoeh COMPLETED 10/04/2010 

See note above 

National Academies Press http://www.nap.edu/ COMPLETED 06/24/2010 

See note above 

NNSA - Nevada Site Office www.nv.doe.gov/main/search.htm COMPLETED 06/24/2010 

See note above 

43 of 44 
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Table A1-2: Database Searches for Norton Co. 

Database/Source Keywords 

NOTE: Database search terms employed for each of the databases listed below are available 

in the Excel file called “Data Capture Synopsis for Norton Co.” 

NRC ADAMS Reading Room http://www.nrc.gov/reading-rm/adams/webbased.html COMPLETED 06/24/2010 

See note above 

USACE/FUSRAP http://www.lrb.usace.army.mil/fusrap/ COMPLETED 06/24/2010 

See note above 

U.S. Transuranium & Uranium Registries http://www.ustur.wsu.edu/ COMPLETED 06/24/2010 

See note above